Legal Opinion
Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided August 29, 1967No. 23153_1PublishedCited by 473 opinions
1Opinion of the Court
RIVES, Circuit Judge:
The taxpayers seek a review of a Tax Court decision holding each of them liable for deficiencies in income tax and some of them liable for penalties pursuant to Sections 6651(a) and 6653(a) of the 1954 Internal Revenue Code.1 There are seven distinct and unrelated issues involved. To facilitate our disposition of this case, we take up each matter separately.
I. Recognition of Gain on the Sale of Carlos and Jacqueline Marcello’s Residence.
Carlos Marcello purchased a residence in July 1946 for $42,500 and sold it in December 1958 for $101,963.85. An Act of Sale, dated March…
2Cases cited38 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Helvering v. MitchellSupreme Court of the United States · 1938
33 more not listed; retrieve them via the Exa API.
3Cited by473 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Freytag v. CommissionerUnited States Tax Court · 1987
- Antonides v. CommissionerUnited States Tax Court · 1988
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
468 more not listed; retrieve them via the Exa API.